The recent conviction of former KBH Andelskasse CEO Bo Stengaard marks a pivotal yet incomplete chapter in one of Denmark’s most alarming money laundering scandals. While Danish media focuses on Stengaard’s four-month suspended sentence, a broader compliance investigation reveals a sophisticated network involving payment firms Clearhaus and FCA-regulated Moorwand. These companies, and the individuals behind them, played instrumental roles in orchestrating the high-risk client flows and systemic AML violations that ultimately led to the bank’s collapse.
Key Points
- Former CEO Bo Stengaard received a suspended sentence after admitting guilt to massive AML failures between 2017 and 2018.
- The bank processed over €550 million in suspicious transactions, mostly from foreign clients referred by fintech partners.
- Clearhaus and Moorwand were not just clients but influential operators, with access to systems and ability to override compliance measures.
- KPMG and court evidence identify Moorwand and UPC Consulting as the main facilitators of high-risk transactions.
- Wael Almaree, Robert Courtneidge, and Alain Bazille are named as central figures behind the scheme.
- Despite Stengaard’s confession, other key players remain unindicted, and the full network remains operational in parts of Europe under new ownership.
Short Narrative
When Bo Stengaard took over KBH Andelskasse in early 2017, he inherited more than just a distressed cooperative bank—he stepped into a financial crime machine. His own admission described a “chaos factory” overridden by fintech pressure, understaffed compliance, and a flood of suspicious clients funneled through Clearhaus, a major shareholder.
Court documents reveal that internal alarms—over 1,600 in a single year—were either ignored or silenced. Stengaard admitted fault, yet painted himself as a powerless middleman. The court agreed—delivering a symbolic sentence but failing to address the broader financial network that enabled the crimes.
The EFRI, an organization representing the opera industry, has been pursuing the people behind Andelskasse and Clearhaus for years. This is due to their role as payment facilitators for fraudulent trading scams. For EFRI, the ruling in Denmark (even if it is lenient) is further proof that without compliant payment processors, fraudulent scam platforms would not be able to defraud people so easily.
Extended Analysis
A Symptom of Regulatory Arbitrage
KBH Andelskasse’s downfall reflects more than one man’s failure; it is a case study in how fintechs exploit regulatory gaps. The Danish FSA’s refusal to approve the board’s preferred CEO led to Stengaard’s reluctant appointment. Meanwhile, Clearhaus and Moorwand—both closely tied to controversial figures—used their influence as clients and shareholders to control onboarding and bypass due diligence protocols.
Clearhaus, acquired by Germany’s Unzer in 2021, pushed the bank to onboard high-risk clients without proper KYC. At the same time, Moorwand, under the leadership of Wael Almaree and Robert Courtneidge, executed a payment scheme involving shell entities like UPC Consulting and ChargePay, all flagged in KPMG’s audit as primary sources of suspicious transfers.
The result: €4.1 billion processed in a single year, most of it without adequate scrutiny. This happened under the nose of Danish regulators, raising further concerns about oversight failure.
The Role of Moorwand and Its Network
FCA-regulated Moorwand Ltd, previously known as UPayCard, was more than a client—it was structurally embedded into KBH Andelskasse’s operations. Moorwand and UPC Consulting were responsible for the majority of red-flagged transfers. Almaree, who was simultaneously beneficial owner of KBH Andelskasse and Moorwand, represents a textbook case of undisclosed related-party risks.
Bazille, Courtneidge, and Almaree all had histories of enabling illegal gambling and fraudulent broker schemes. Their companies were facilitators for binary options scams and other illicit ventures across Europe. Yet despite these connections, Moorwand remains licensed under the UK FCA, a point that deserves serious regulatory reevaluation.
The Clearhaus–Unzer–Moorwand Triangle
The influence of fintech extends beyond Denmark. Clearhaus, a central figure in the scandal, was acquired by Unzer, itself formerly owned by KKR. Unzer and its group faced onboarding bans and AML-related fines in Luxembourg and Germany. These cascading scandals reveal a pan-European fintech laundering network with Denmark as a convenient weak link.
Actionable Insight
This case demands a cross-border regulatory response. The suspended sentence for Stengaard is only meaningful if it serves as a starting point for further indictments. FinTelegram urges Danish, German, and UK regulators to reopen investigations into:
- The role of Clearhaus under Unzer leadership,
- The current operations of Moorwand Ltd and its license status,
- The legal responsibility of Wael Almaree, Alain Bazille, and Robert Courtneidge.
A coordinated inquiry by DFSA, FCA, and BaFin could expose ongoing threats to financial integrity across the EU and the UK.
KBH Andelskasse Compliance Scandal – Network Summary Table
| Name / Entity | Role | Connection | Notes |
|---|---|---|---|
| Bo Stengaard | Former CEO of KBH Andelskasse | Admitted guilt in AML failures; received a 4-month suspended sentence | Claimed pressure from Clearhaus; portrayed himself as a reluctant manager of a “chaos factory” |
| KBH Andelskasse | Danish cooperative bank (now defunct) | Processed €550M+ in suspicious transactions; taken over by Finansiel Stabilitet | Used as a channel for money laundering via fintech clients |
| Clearhaus A/S | Danish payment processor | Major shareholder and client of KBH Andelskasse | Funneled high-risk clients to bank; acquired by Unzer in 2021 |
| Unzer Group | German fintech (formerly Heidelpay) | Acquired Clearhaus in 2021; previously owned by KKR | Under regulatory scrutiny in Germany and Luxembourg for AML control failures |
| Moorwand Ltd | FCA-regulated e-money institution (formerly UPayCard) | Major source of suspicious transactions via KBH Andelskasse | Controlled by Almaree, previously by Bazille and Courtneidge; involved in illegal broker scams |
| UPC Consulting Ltd | UK-based shell company | Connected to Moorwand; received and facilitated suspicious transactions | Controlled by Alain Bazille; mentioned in KPMG’s list of high-risk clients |
| ChargePay | Client of KBH Andelskasse | Part of the “Moorwand Payment Scheme” | Helped process fraudulent transactions alongside Moorwand and UPC Consulting |
| Wael Almaree | British-Moldovan financier | Beneficial owner of KBH Andelskasse and Moorwand; investor in Clearhaus via WN International Group ApS | Central figure; avoided indictment despite evidence of deep involvement |
| Robert Courtneidge | UK payments lawyer / consultant | Director of Moorwand; involved in KBH Andelskasse client operations | Resigned in 2019; connected to other payment providers |
| Alain Bazille | Payment facilitator / entrepreneur | Founder of Moorwand and UPC Consulting; main client of KBH Andelskasse | Linked to binary options scams and illegal gambling |
| WN International Group ApS | Almaree’s Danish investment vehicle | Held shares in KBH Andelskasse and Clearhaus | Used to establish control in Danish fintech ecosystem |
| KPMG | Auditing firm | Identified Moorwand, UPC Consulting, and ChargePay as primary suspicious clients of KBH Andelskasse | AML audit disclosed massive compliance failures |
Call for Information
FinTelegram calls on whistleblowers, former employees, and compliance officers with insights into KBH Andelskasse, Moorwand, Clearhaus, or Unzer to come forward. Submit documents or leads confidentially via Whistle42.com and join our effort to uncover the full scope of this laundering network.
